{
    "name": "Amundi UK Equity All Cap UCITS ETF Dist",
    "type": "ETF",
    "ucits": true,
    "leverage": false,
    "derivatives": true,
    "swaps": true,
    "inverse": false,
    "replication_method": "physical",
    "complex_factors": [
        "OTC Swaps",
        "Counterparty Risk"
    ],
    "classification": "complex",
    "supporting_data": "The ETF primarily uses physical replication but also employs OTC swaps with counterparties like Morgan Stanley Bank AG and Societe Generale, which introduces complexity due to counterparty risk exposure. While the replication method is physical, the use of swaps for optimization and the associated counterparty risks (limited to 10% of fund assets per UCITS guidelines) contribute to its classification as complex under MiFID II. The presence of operational and liquidity risks further supports this assessment.",
    "confidence": 85,
    "risk_level": 4,
    "counterparty_risk": true,
    "liquidity_risk": true,
    "benchmark_complexity": false,
    "comprehension_warning": false,
    "additional_notes": "Although the ETF is physically replicated and UCITS-compliant, the use of OTC swaps and the associated counterparty risks, even within regulatory limits, introduces elements that may not be easily understood by retail investors. This, combined with the operational and liquidity risks disclosed, aligns with MiFID II criteria for complex instruments."
}